62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`STATE OF MINNESOTA
`
`COUNTY OF RAMSEY
`
`Trafera, LLC and Trafera Holdings, LLC
`
`Plaintiffs,
`
`vs.
`
`Jason Gordon, Vivacity Tech PBC, Eli
`Maloley, and Ben Erickson,
`
`Defendants.
`
`I, Jason Gordon, hereby declare:
`
`DISTRICT COURT
`
`SECOND JUDICIAL DISTRICT
`Case Type: Contract
`
`Case No.: 62-CV-22-5644
`The Honorable Mark R. Ireland
`
`DECLARATION OF JASON GORDON
`IN OPPOSITION TO MOTION FOR
`TEMPORARY INJUNCTION AND
`EXPEDITED DISCOVERY
`
`1.
`
`I am the Vice President of Procurement at Vivacity Tech PBC and a named
`
`Defendant in this lawsuit. I make this declaration based upon my own personal knowledge
`
`of the contents contained herein.
`
`2.
`
`I have worked in procurement and distribution in the classroom technology
`
`industry for approximately 27 years. Over that time, I have built relationships with sales
`
`representatives of many original equipment manufacturers (“OEM”) and distributors of
`
`OEM products who provide computers and other technology for classroom use, as I worked
`
`with many of the same OEMs and distributors at each company during my career. I also
`
`gained important insights into the operational efficiencies of the technology distribution
`
`and reseller industry.
`
`3.
`
`I take pride in my work, both because of the experience I’ve gained over
`
`decades in the classroom technology industry, but also because I am the sole breadwinner
`
`for my family. Since approximately 2008, my wife has worked in the home caring for our
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`two youngest children, now ages 10 and 13. My wife previously worked as a cross-country
`
`coach and mentored a student who experienced extreme difficulty at home, and was
`
`involved in several runaway situations. We eventually took legal custodial guardianship of
`
`the boy when he was 15-years-old, striving to provide him with a stable, loving, and
`
`supportive home environment. He’s now 22-years-old, and we are proud to support his
`
`higher education goals by paying his academic and living expenses.
`
`4.
`
`In March 2020, I joined FireFly Computers, LLC (“FireFly”), as its Director
`
`of Purchasing. I had known one of FireFly’s owners, Devang Shah, for many years and he
`
`recruited me to FireFly from my previous employer. I signed an employment agreement
`
`with FireFly at the outset of my employment.
`
`5.
`
`I initially enjoyed working for FireFly. It built its business on the quality of
`
`the service it provided and a “win with the customer” mentality. Although I held a director-
`
`level position, I felt that I had a seat at the table and that my voice mattered to FireFly’s
`
`senior leadership team.
`
`6.
`
`A few months after I started working at FireFly, in September 2020, FireFly
`
`announced it was merging with Trinity3 Technology (“Trinity3”) to form a new entity
`
`effective January 1, 2021. I was concerned, as Shah repeatedly reassured me when I joined
`
`FireFly that he did not intend to sell the company.
`
`7.
`
`For months after the announcement, many FireFly employees (including me)
`
`were left in the dark if we would even have jobs following the merger. I discussed my
`
`concerns with Shah, who dismissed them and promised that I would be financially
`
`rewarded for staying on with the new business.
`
`2
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`8.
`
`On December 30, 2020, I finally received a letter from Trafera, LLC
`
`(“Trafera”) offering me the position of Vice President – Procurement in the new business.
`
`Although ostensibly a promotion in title, the offer represented a reduction in my base
`
`salary. The offer letter also mentioned an annual incentive bonus based on performance
`
`objectives to be determined by Trafera’s ownership. The performance objectives for my
`
`bonus were never shared with me, if they were ever formally determined at all.
`
`9.
`
`The December 30, 2020 letter also stated the compensation details in the
`
`letter would supersede the compensation details in my FireFly employment agreement. I
`
`assumed that simply meant what it said: I would no longer receive the compensation set
`
`forth in my employment agreement with FireFly. That didn’t surprise me because I
`
`assumed I would no longer be a FireFly employee.
`
`10.
`
`I accepted the position with Trafera with serious reservations and began the
`
`new position with the new business in January 2021. Whereas I previously had managed
`
`the procurement department, I now reported to Mike Miller, Senior Vice President –
`
`Procurement and Service. I also stopped being paid by FireFly and began getting paid by
`
`Trafera. Attached hereto as Exhibits 1 and 2 are, respectively, my 2020 and 2021 W-2s,
`
`which show the change in my employer.
`
`11.
`
`Other than the December 30, 2020 letter, I never received a new employment
`
`agreement to sign after I began working for Trafera. Based on my prior experience, I
`
`thought that was very odd. I had previously worked for companies that were acquired or
`
`merged and was provided new employment documents each time. I specifically asked
`
`Shah, who continued on as a board member of Trafera, whether I remained subject to the
`
`3
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`employment agreement I signed with FireFly. Shah stated he thought so, but he was not
`
`certain if that was the case.
`
`12.
`
`As Vice President – Procurement at Trafera, I was responsible for acquiring
`
`only new (not recertified) technology from OEMs and distributors; another employee was
`
`responsible for acquiring recertified devices. I also maintained limited data in spreadsheets
`
`used by Trafera’s sales team regarding Trafera’s inventory and the minimum margins
`
`Trafera could accept to make a profit on a sale—but I did not set those margins. Any
`
`changes I made to the spreadsheet were approved by Mike Miller.
`
`13.
`
`I also coordinated with OEM sales representatives and other distribution
`
`partners, many of whom I had worked with in my years before joining FireFly, although I
`
`was not the only one responsible for maintaining these relationships. Every procurement
`
`employee worked directly with Trafera’s OEMs and distribution partners. Miller
`
`personally managed Trafera’s relationship with Lenovo, one of its largest OEMs. Based on
`
`my approximately 25 years in the industry, many of Trafera’s OEM and distributor contacts
`
`already knew me before either Trafera or FireFly even existed. I rarely, if ever, had contact
`
`with Trafera’s customers.
`
`14.
`
`Further, Trafera buys from the OEMs and distributors, who gladly sell their
`
`products to any willing buyer. My pre-existing relationship with some of their sales
`
`representatives did not help me secure better customer contracts for Trafera.
`
`15.
`
`Trafera’s business model is significantly different than Vivacity’s business
`
`model in terms of size and scope. Trafera’s competitive edge is based on economies of
`
`scale. Vivacity does not have nearly the buying power of Trafera. Trafera maintains
`
`4
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`significant inventory that it purchases at volume discounts that are not available to Vivacity
`
`based on Vivacity’s smaller buying power. Furthermore, much of the products Trafera
`
`purchases are obtained via customer contracts called “deal registrations” that are not
`
`transferable to Vivacity.
`
`16.
`
`I have reviewed the Declaration of Scott Gill submitted in support of
`
`Trafera’s motion for a temporary injunction. In Paragraphs 9-10, Gill asserts I had access
`
`to Trafera’s confidential information. As far as I am aware, every Trafera employee had
`
`access to this same confidential information. Moreover, most of Trafera’s customer
`
`contracts are public knowledge because the school districts to which it sells are public
`
`entities. Even if I had access to the information Gill lists, I did not use or look at most of it
`
`as it did not pertain to my duties in procurement.
`
`17.
`
`Even if I attempted to memorize the information I used regularly, that
`
`information would quickly grow stale. Distributors regularly update the prices they charge
`
`to buyers such as Trafera. I do not understand how such information could be used to
`
`negotiate a different price from the same distributors most Trafera competitors also already
`
`use.
`
`18.
`
`I did not consult with Trafera’s sales representatives regarding offers being
`
`made to schools and had no reason to review customer contract terms. In fact, I was
`
`discouraged from consulting with sales representatives. As an example, I once discussed a
`
`procurement deal from one of our distributors with a colleague in the sales department. All
`
`such purchases required me to get approval from the Senior Vice President of Purchasing,
`
`5
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`who did not approve the purchase. I was later scolded by the Senior Vice President after
`
`he was asked why he had not approved the purchase.
`
`19.
`
`In late April or early May of 2021, Trafera presented me with the “Waterfall
`
`Agreement” attached as Exhibit C to Scott Gill’s Declaration. I understood this to be the
`
`“reward” Shah had promised, although it was far from what I expected. It appeared to be
`
`contingent on numerous factors entirely outside my control and left full discretion to issue
`
`any bonus payment to Trafera’s board. It also included restrictive covenants I had not been
`
`told I would have to accept.
`
`20.
`
`The Waterfall Agreement also notes several key terms are defined in Trafera
`
`Holdings, LLC’s “Third Amended and Restated Limited Liability Company Agreement.”
`
`I do not recall ever receiving a copy of this LLC agreement. I have only been an employee
`
`of Trafera, LLC. I am not, and never have been, a member of Trafera, LLC or Trafera
`
`Holdings, LLC.
`
`21.
`
`Rather than a reward for growing Trafera, Scott Gill presented the Waterfall
`
`Agreement to me as a “take it or leave it” arrangement. He stated during a meeting that I
`
`would be considered a “flight risk” if I did not sign the Waterfall Agreement. I reluctantly
`
`signed the document.
`
`22.
`
`Over the course of the next year, I grew more frustrated with what I saw as
`
`Trafera’s poor management and treatment of its employees. I consistently worked 60-80
`
`hour week while watching other employees leave Trafera. I realized I was burned out.
`
`23.
`
`On August 8, 2022, I submitted my resignation to Trafera and gave my last
`
`day of work as August 19, 2022. I intended to spend a few weeks at home with my family
`
`6
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`before my children returned to school, at which time I would begin looking for a new job.
`
`I met with Gill and explained that I felt burned out and did not believe Trafera was being
`
`effectively managed, and that I needed some time off before I make my next move. He
`
`asked me to stay until September 2, 2022 to assist with the transition, which I agreed to do
`
`on a part-time basis.
`
`24.
`
`Before I left Trafera, I sat down with two Trafera company employees to
`
`review and return any potentially confidential information I had. Besides returning my
`
`work laptop, I brought in my personal computer and USB drives. I also showed that I had
`
`wiped everything from my cloud-based accounts. I have not been subsequently contacted
`
`by Trafera with any concerns that I still had anything in my possession they believed to be
`
`confidential.
`
`25.
`
`After taking some time with my family, I went to work for Vivacity as Vice
`
`President for Procurement. Although my title is similar, I have a much broader role that
`
`includes the procurement of products Trafera does not carry. I have not used any
`
`confidential information from Trafera in my new position.
`
`26.
`
`Gill’s Declaration notes a Lenovo sales representative emailed my old
`
`Trafera email address on October 14, 2022, which he believes to mean that I have already
`
`engaged in negotiations with Lenovo for Vivacity. That is not true. I have not engaged in
`
`negotiations with any OEMs on behalf of Vivacity to date. Without the benefit of seeing
`
`the alleged email, I assume the representative sent one of the many unsolicited sales emails
`
`that individuals in my position regularly receive from sales representatives.
`
`7
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`27.
`
`Vivacity already has existing business relationships with many of the same
`
`OEMs and distribution partners as Trafera.
`
`I declare under penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
`
`Dated this 21st day of October, 2022 in _______________________, _______________.
`[county]
`[state]
`
`Jason Gordon
`
`8
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`
`10/21/2022 1:59 PM
`
`EXHIBIT 1
`
`

`

`>'E
`
`mm
`
`NE
`
`N
`N
`Q0>5
`8
`
`.=
`
`NE—
`
`3
`
`FOLDANDDETACH
`
`2020
`W2 & EARNINGS
`SUMMARY
`
`FIREFLY COMPUTERS, LLC
`1271 RED Fox ROAD
`SAINT PAUL. MN 55112
`
`62-CV-22-5644
`
`a
`
`SOClal security number
`
`Emiloiee's
`0 Employer's name. address. and ZIP code
`FIREFLY COMPUTERS, LLC
`1271 RED FOX ROAD
`SAINT PAUL, MN 55112
`b Employer's identification number
`45-2430649
`e Employee's name and address
`JASON EVERETT GORDON
`216 4TH STREET SE
`PIPESTONE, MN 56164
`
`d Control Number
`116770-299
`
`JASON EVEfii'sTlr GORDON
`
`FlTWH
`MN
`
`Filing Status Exemptions
`M
`M 3
`
`OTHER
`Dessn'plion
`401k
`WAGES
`TOTAL GROSS VAGES
`
`j
`
`Annual
`4935.21
`
`12
`
`495730.95
`
`f1
`
`1'
`IT'S FAST. IT'S SAFE IT'S FREE.
`
`15 state & Employer's state ID
`2118720
`MN
`
`|
`
`16 State wages,fips.etc 17 State Income tax
`490635.72
`40592.53
`
`18 Local wages,tips.etc. 19 Local Income tax
`
`20 Locality name
`
`a Employees see a securly numEer
`
`I
`c Employer's name. address, and in5 code
`FIREFLY COMPUTERS, LLC
`1271 RED FOX ROAD
`SAINT PAUL, MN 55112
`b Employer's idenlificalion number
`45-2430649
`5 Employee's name and address
`JASON EVERETT GORDON
`216 4TH STREET SE
`PIPESTONE, MN 56164
`
`:1 Control Number
`116770-299
`
`1 Wagesfipsplher compensallon
`490635 72
`3 Soclal securlty wages
`7700.00
`wages an tlps
`495570.93
`
`2 Federal income tax
`1 5423.80
`4 Social security tax
`
`3
`5 Mealcare lax wfihea
`4
`
`ocae
`
`ps
`
`0
`
`3
`
`10 Depenaenl care Eenefié
`
`12 See instrs. for box 12
`onquax e pans
`4935.21
`DI
`13 Stat emp Ret. Plan 3 Party 8le DD
`160.02
`X
`
`14 Other
`
`15 Slate & Employer's slate ID
`2118720
`N
`M |
`
`16 Stale wages,ups,etc 17 State income tax
`40592.53
`490635.72
`
`18 Localwages,nps,elc. 19 Local income tax
`
`20 Locality name
`
`a
`
`social security number
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`N
`N
`
`1 Wagestipsplhercompensation
`490635
`.72
`3 Social security wages
`1 7700.00
`5 Medlcare wages and tips
`495570.93
`Social securlty tips
`
`2 Federal income tax
`135423.80
`4 Social security tax
`8537.40
`6 Medicare lax withheld
`9845.93
`
`8 Allocated €35
`
`10 Dapen ant care benefiE
`
`.3; ..
`
`p BITS
`
`12 Sea instrs. for box 12
`onqual e
`4935.21
`DI
`15 §lalemp. Rel. Fan 5Farly §IcH DD
`160.02
`X
`I 51hr
`
`4}
`
`.OLDANDDETAC:
`
`N
`N
`
`>.'o-I
`
`my
`
`LI.
`
`§ 8'83
`NE
`
`Description
`Sec. Security Wages
`Medicare Wages
`Fed.TaxableWarges
`MN Taxab|e Wages
`WiTHHOLDINGS
`Description
`Fed. Income Tax
`Soc. Security Tax
`Medicare Tax
`MN Income Tax'
`DEDUCTIONs
`Qescn'gtion'
`401(k) Plan "
`Health125 Deduction
`
`>
`Amgunt Mai);
`137700.00
`405570.93
`490635.72
`490635.72
`
`16L
`V
`Amount fig
`135423.80
`2
`8537.40
`4
`9845.93
`6
`40592.53
`17
`
`Am
`
`4935.21
`160.02
`
`12
`12
`
`Emiloiee's
`c Employer's name. address. and Z-lP code
`FIREFLY COMPUTERS, LLC
`1271 RED FOX ROAD
`SAINT PAUL, MN 55112
`b Employer's identification number
`45—2430649
`e Employee's name and address
`JASON EVERETT GORDON
`216 4TH STREET SE
`PIPESTONE, MN 56164
`
`d Control Number
`116770-299
`
`1 Wages,trps.other compensation
`490635.72
`3 Social security wages
`1 37700.00
`wages and tips
`495570.93
`7 Social secunty tips
`
`5
`
`..
`
`2 Federal income tax
`1 5423.80
`4 Social security tax
`537.40
`8
`6 Medicare lax withheld
`9845.93
`
`8 Allocated tips
`
`9
`
`10 Dependent care Benefits
`
`onquer e n'ans
`
`91.
`
`Ian
`
`any
`
`tel amp.
`I flier
`
`12 See lnstrs. for box 12
`4935.21
`160.02
`
`Ic DD
`
`15 State & Employer's slate ID
`2118720
`MNl
`
`16 state wages,lips,etc
`490635.72 l
`
`7 state Income tax
`40592.53
`
`15 Local wages,tlps,etc.
`
`Local Income tax
`
`20 Locallty name
`
`'19
`
`I
`
`P code
`
`FIREFLY COMPUTERS, LLC
`1271 RED FOX ROAD
`SAINT PAUL, MN 55112
`b Employer's Identlfication number
`45-2430649
`a Empmyaes we're ard adC'Ess
`JASON EVERETT GORDON
`216 4TH STREET SE
`PIPESTONE, MN 56164
`
`11 Control Number
`116770-299
`
`1 Wages.tlps,othercompensafion
`635 72
`3 Social sscurlty wages
`700.00
`wages an
`ps
`495570.93
`7 §oc a secumy ups
`
`2 Faderal income tax
`135423.80
`4 Soclal securfly tax
`37.40
`9845.93
`
`8Aocae ps
`
`n
`
`15 Dependent care Benefits
`
`onqual e" pans
`
`12 See lnslrs. for box 12
`DI
`4
`13 Stat emp. ReK. Plan 3 Pany SIC DD
`X
`14 other
`
`93
`5.21
`160.02
`
`E..-
`
`.E;
`
`1PaY
`
`ZOIZ'
`
`15 State & Employer's Mate ID
`21 18720
`MNI
`
`16 State wages,tips,etc 17 Stateinconme tax
`490635.72
`40592.53
`
`18 Local wages.fips,etc. 19 Local incomelax
`
`20 Locality name
`
`

`

`For Official Use Only >
`uuuuu
`OMB No. 1545-0008
`a Employer's name, address, and ZIP code
`
`FIREFIJY COMPUTERS ,
`1271 RED FOX ROAD
`SAINT PAUL, MN 55112
`
`LLC
`
`b Emplo
`4 5 -2 4
`
`r's Federal EIN
`0 6 4 9
`
`62-CV-22-5644
`
`Safe. accurate,
`FAST! Use
`c Tax year/Form corrected
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`\fisit the IRS website
`at www.irs.gov.
`d Employee's correct SSN
`
`2020
`/W-2
`a Corrected SSN and/or name (Check this box and complete boxes fand/or
`g if incorrect on form previously filed.)
`Complete boxes f and/or g only if incorrect on form previously filed >
`f Employee's previously reported SSN
`
`g Employee's previously reported name
`
`«'urillz'flllwr?
`
`llllr::ll;:.».
`
`aki=llliistx n
`
`h Employee's first name and initial
`JASON EVERETT
`2 l 6 4TH STREET SE
`Note: Only complete money fields that are being corrected (exception: for PI PESTQNE , MN 5 6 1 6 4
`corrections involving MQGE, see the General Instructions for Forms W-2
`and W-3, under Specific Instructions for Form W-2c. boxes 5 and 6).
`Correct information
`Previously reported
`1 Wages tips, other compensation
`1 Wages, tips, other compensation
`490,l04.72
`490,635.72
`3 Social security wages
`3 Social security wages
`
`Last name
`GORDON
`
`Suff.
`
`2
`
`Correct information
`Federal income tax withheld
`135,436.28
`4 Social security tax withheld
`
`i Employee's address and ZIP code
`Previously reported
`Federal income tax withheld
`135,423.80
`4 Social security tax withheld
`
`2
`
`5 Medicare wages and tips
`495,570.93
`7 Social security tips
`
`5 Medicare wages and tips
`495,039.93
`7 Social security tips
`
`6 Medicare tax withheld
`
`8 Allocated tips
`
`9,845.93
`
`6 Medicare tax withheld
`9,833.45
`
`8 Allocated tips
`
`9
`
`9
`
`10 Dependent care benefits
`
`1O Dependent care benefits
`
`See instructions for box 12
`See instructions for box 12
`gZa
`12a
`160.02 EDD
`691.02
`§DD
`12b
`
`|
`
`|
`
`32b
`
`11 Nonql aimed plans
`
`11 Nonqualified plans
`
`13
`
`D
`D
`14 Other see instructions)
`
`D
`
`13
`
`D
`D
`14 Other (see instructions)
`
`D
`
`|
`
`l
`
`12c
`
`12d
`E
`2
`
`'é
`
`12c
`
`12d
`I E
`
`l
`
`l
`
`I
`
`Correct information
`15 State
`
`Previously reported
`15 State
`MN
`
`State Correction Information
`Correct information
`Previously reported
`15 State
`15 State
`MN
`
`Employer's state ID number
`2118720
`16 State v ages, tips, etc.
`490, 635.72
`
`17 State income tax
`
`Employer" s state lD number
`2118720
`16 State wages. tips, etc.
`490,104.72
`
`17 State income tax
`
`Employer's state ID number
`
`Employer's state lD number
`
`16 State wages. tlps, etc.
`
`16 State wages, tips, etc.
`
`17 State income tax
`
`17 State income tax
`
`Previously reported
`18 Local wages, tips, etc.
`
`Locality Correct on Information
`Correct information
`Previously reported
`18 Local wages. tips, etc.
`18 Local wages, tips, etc.
`
`Correct information
`18 Local wages, tips, etc.
`
`19 Local income tax
`
`19 Local income tax
`
`19 Local income tax
`
`19 Local income tax
`
`20 Locality name
`
`20 Locality name
`
`20 Locality name
`
`20 Locality name
`
`Form W--2c (Rev. 8-2014)
`
`Copy B—To Be Filed with Employee's FEDERAL Tax Return
`Department of the Treasury
`Corrected Wage and Tax Statement
`Internal Revenue Service
`
`

`

`62-CV-22-5644
`
`Filed in District Court
`State of Minnesota
`
`10/21/2022 1:59 PM
`
`EXHIBIT 2
`
`

`

`f.
`
`L.
`Copy B-To Be Filed With Employee's
`FEDERAL Tax Return
`a. Employee's soc. sec. no.
`
`W'2 Statement
`Wage and Tax
`-1. Wages, tips. other comp
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`OMB No. 1545-0008
`
`2021
`2. Fed. Income tax withheld
`33304.96
`4. Soc. sec. tax withheld
`8853.60
`6. Medicare tax Withheld
`3616.65
`
`b. Employer ID number (EIN)
`30—1211432
`d. Control number
`84464-FF299
`c. Employer's name, address. and ZIP code
`TRAFERA LLC
`2550 University Ave W Ste 315-5
`St Paul, MN 55114
`e. Employee's name, address, and ZIP code
`Jason E Gordon
`420 6th Ave E:
`Alexandria, ,MN . 56308
`7. secial security tips
`
`a. Allocated'tips
`
`10. Dependent care benefits
`
`'
`
`~~
`
`".3, Statutory arrpioyee
`
`11. Ncnouai"ied plans
`
`.,
`
`14 Other
`
`Retirement
`
`'
`
`'
`
`'an.
`
`,,
`
`,,
`
`Y
`
`Third~party slc'k pay
`
`62-CV-22-5644
`
`Wa
`
`d T
`
`ax
`
`state, City, or Local Income Tax Return W'z Stagmaennt
`Copy 2-To Be Filed With Employee's
`a. Employee's soc. sec. no.
`1. Wages, tips. other comp
`213695.81
`3. Spoial security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`b. Employer 1D number (EIN)
`30—1211432
`d. Control number
`84464-FF299
`c. Employer's name, address, and ZIP code
`TRAFERA LLC
`2550 University Ave W Ste 315—3
`St: Paul, MN 55114
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`
`Ii
`
`.1
`0MB N . 1545-0008
`o
`
`2021
`2. Fed. income tax Withheld
`33304.96
`4. Sec. sec. tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`e. Employee's name, address. and ZIP code
`Jason E Gordon
`420 6th Ave E
`Alexandzia, MN 56308
`7. Social security tips
`
`13, Allocated tips
`
`10. Dapenccnt care 'cenefts
`
`1'. Nonquaiifieo' plans
`
`13 Statutory employee
`
`14. Other
`
`'
`
`Retirement plan
`
`-9
`
`12a, Code
`on
`12:). Code
`D
`
`'"
`
`2o. (gods ,,
`
`17.oj;,,'..eo
`
`16799.90
`"'
`
`125. Code
`
`~
`
`,3:
`
`Thirdwpariy sick pay
`
`12a. Code
`a:
`12b. Ccce
`,. 16799.90.
`)D
`120. code'i
`5""
`
`12d. cude'
`
`15. State
`MN
`
`Employer's state ID no.
`6538411
`
`16. State wages, tips, etc,
`213695.81
`
`17.State income tax
`12572.61
`
`15. State
`MN
`
`Employer's state it) no.
`6538411
`
`16. State wages, tips, etc.
`213695.81
`
`17.81ate income tax
`12572.61
`
`18. Local wages. tips, etc .
`
`19. Lcmal income tax
`
`20. Locality name
`
`18. Local wages, tips. etc..
`
`19. Local income tax
`
`20. Locality name
`
`Department of the Treasury — interna Revenue Service
`
`OMB No. 1545-0003
`
`2021
`2. Fed. income tax withheld
`33304.96
`4. Soc. sec. tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`I
`
`Department of the Treasury - lntema Revenue Service
`This information is being furnished to the Intemai Revenue Service.
`
`can c~F
`EMPLO'IEE's RECORDS
`(SeeyNaflczrto Employee)
`a. Em in ee's soc. see. no.
`
`W eand Tax
`
`w'z sggement
`1. Wages, tips. other comp
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`b. Employer in number (EIN)
`30-1211432
`(1. Control number
`84464—E'F299
`cfmpioyer's name, address, and'ZVIii 66d;
`TRAFERA LLC
`2550 University Ave W Ste 315wS
`St Paul, MN 55114
`e Employee's name, address, and Zip code
`Jason E
`,,,,420 car.
`" Alexandria,"'i/il\i 56308
`7 SOCIaI seconty i.p§
`
`8. A.icoa'.ec tips
`
`10. Dependent care benefits
`
`11. Nonquallfied plans
`
`13. Statutory employee
`
`14. Other
`
`Retirement plan
`
`Y
`
`Third-party sick pay
`
`9
`
`'
`
`)
`
`4
`
`12a. Code
`DD
`
`12b. Code
`D
`
`12c. Code
`
`12d. Code
`
`ee's
`
`w e and Tax
`
`State, City: or Local Income Tyaixzeturn W'2
`Copy 2—r Be F'Ied With Em I
`a. Employee's soc. sec. no.
`1. Wages. tips. other comp
`213695.81
`b. Employer lD number (EN)
`3. Social security wages
`142800.00
`30*1211432
`5. Medicare wages and tips
`d. Control number
`7230495371
`84463fl'FF299
`.
`c. Employer's name, address, and ZIP code
`I TRAFERA LLC
`2550 University Ave W Ste 315—8
`St. Paul, MN 55114
`e. Employee's name, address, and ZIP code
`7
`(Bord:n
`.. PM:
`E
`Alexandria, MN 56308
`7 Somai secu'ity' tips
`
`J.
`4
`
`"
`
`8 Allocaiec i'ps
`
`17071.60
`
`16799.90
`
`10. Dependent care benefits
`
`11. Nonqualitied plans
`
`13. Statutory employee
`
`14. Other
`
`Retirement plan
`
`Y
`
`Third-party sick pay
`
`OMB N . 1545-0003
`o
`
`2021
`2. Fed. incorne tax withheld
`33304.96
`4. Soc. sec. tax withheld
`8853.60
`6. Medicare tax Withheld
`3616.65"
`
`9
`
`w
`
`»
`
`.
`
`12a. Code
`DD
`
`12b. Code
`D
`
`12c. Code
`
`12d. Code
`
`17071.60
`
`16799.90
`
`15. State
`MN
`
`Employer's state lD no.
`6538411
`
`16. State wages. tips, etc.
`213695.81
`
`17.State Income tax
`12572.61
`
`15. State
`MN
`
`Employer's state ID no.
`6538411
`
`16. State wages, tips, etc.
`213695.81
`
`17.State income tax
`12572.61
`
`18. Local wages, tips, etc..
`
`19. Local income tax
`
`20. Locality name
`
`16. Local wages, tips. etc..
`
`19. Local income tax
`
`20. Locality name
`
`Department of the Treasury— Intema Revenue Service
`If you are required to file a tax return, a
`This information is being furnished to the Internal Revenue Sen/ice .
`negligence penaity or other sanction may be imposed on you if this income is taxable and you fail to report it.
`
`Department of the Treasury —— lntema Revenue Servrce
`
`

`

`62-CV-22-5644
`
`Copy B—To Be Filed With Employee's FEDERAL Tax Return
`This information Is being lumlshed to the Inlemal Revenue Service.
`a. Employee's social
`number
`1. Wages. tips, other compensation
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`sewi'
`[3. Employer lD number (EIN)
`30-1211432
`d. Control number
`84464-FE'299
`c. Employers name, address. and 27' code
`TRAFERA LLC
`2550 University Ave W Ste 315-5
`St Paul, MN 55114
`
`OMB No. 1545-0008
`
`2. Federal income tax withheld
`33304.96
`4. Social security tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`Copy 2—To Be Filed with Employee's State, City,
`or Local Income Tax Return
`a. Employee's social security number
`
`1. Wages, tips, other compensation
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`b. Employer ID number (EIN)
`30-1211432
`d. Control number
`84464-FF299
`c. Employer's name. address, and ZIP code
`TRAFERA LLC
`2550 University Ave W Ste 315-5
`St Paul, MN 55114
`
`Filed in District Court
`State of Minnesota
`10/21/2022 1:59 PM
`OMB No. 1545-0008
`
`2. Federal income tax withheld
`33304.96
`4. Social security tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`e. Employee's name. address. and ZlP code
`Jason E Gordon
`420 6th Ave E
`Alexandria, MN 56308
`
`e. Employee's name, address. and ZIP code
`Jason E Gordon
`420 6th Ave E
`Alexandria, MN 56308
`
`7 Soc.a1secur.ty:1ps
`
`8 AHocated tips
`
`m,
`
`n
`
`7 Sociai secumy :ips
`
`a. Aiiocazec tips
`
`10. Dependent care benefits
`
`11. Nonqualified plans
`
`13. Statutory employee
`
`14. Other
`
`123. Code See inst. for Box 12
`17071.60
`DD
`12b. Code
`D
`
`16799.90
`
`10. Dependent care benefits
`
`11. Nonqualified plans
`
`13. Statutory employee
`
`14. Other
`
`Retirement plan
`
`Third-parry sick pay
`
`1 2c. Code
`
`12d. Code
`
`Retirement plan
`
`Third-party sick pay
`
`12a. Code See Inst. for Box 12
`17071.60
`DD
`
`16799.90
`
`12b. Code
`D
`
`12c. Code
`
`12d. Code
`
`15. State
`MN
`
`Employer's state ID number
`6538411
`
`16. State wages, tips, etc.
`213695.81
`
`17.State income tax
`12572 . 61
`
`15. State
`MN
`
`Employers state ID number
`6538411
`
`16. State wages, tips, etc. 17.State income tax
`213695.81
`12572 . 61
`
`18. Local wages, tips, etc
`
`19. Local income tax
`
`20. Locality name
`
`18. Local wages, tips, etc.
`
`19. Local income tax
`
`20. Locality name
`
`Form W-2 Wage— and Tax Statement
`
`2021 Depam'nent 0' the Treasury lmemal Revenue Service
`
`Form W-2 Wage and Tax Statement
`
`2021 Department ofme Treasury- lntemal Revenue Service
`
`a Notice to Employee.)
`ll you are raqulred to file a tax
`is information Is belng lumished to the Internal avenue Sen/lee.
`remm. e negligsnm penalty or omet sanction may be Imposed on you it this inmma is taxable sue you
`tail to NM
`21. Employee's social security number
`
`1. Wages. tips, other compensation
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`b. Employer ID number (EIN)
`30-1211432
`d. Control number
`84464-FF299
`c. Employer's name. address, and ZIP code
`TRAFERA LLC
`2550 University Ave W Ste 315-5
`St Paul, MN 55114
`
`OMB No. 1545-0008
`
`2. Federal income tax withheld
`33304.96
`4. Social security tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`Copy 2—To Be Filed With Employee's State, City.
`or Local Income Tax Return
`a. Employee's social security number
`
`1. Wages. tips, other compensation
`213695.81
`3. Social security wages
`142800.00
`5. Medicare wages and tips
`230495.71
`
`b. Employer ID number (EIN)
`30-1211432
`d. Control number
`84464-FF299
`c. Employer's name, address. and ZIP code
`TRAFERA LLC
`2550 University Ave W Ste 315-5
`St Paul, MN 55114
`
`OMB No. 1545-0008
`
`2. Federal income tax withheld
`33304.96
`4. Social security tax withheld
`8853.60
`6. Medicare tax withheld
`3616.65
`
`e. Employee's name, address, and ZIP code
`Jason E Gordon
`420 6th Ave E
`Alexandria, MN 56308
`
`7 Soc aI secdrlty tips
`
`8 Alocated tips
`
`10. Dependent care benefits
`
`11. Nonqualifisd plans
`
`13. Statutory employee
`
`14. Other
`
`Retirement plan
`
`Third-party sick pay
`
`e. Employee's name, address. and ZIP code
`Jason E Gordon
`420 6th Ave E
`Alexandria, MN 56308
`
`7 Socral security tips
`
`8 Alloca:ed has
`
`12a. Code See Inst. for Box 12
`17071.60
`DD
`12b. Code
`D
`
`16799.90
`
`10. Dependent care benefits
`
`11. Nonquallfled plans
`
`13. Statutory employee
`
`14. Other
`
`12a. Code See Inst. for Box 12
`17071.60
`DD
`12b. Code
`D
`
`16799.90
`
`12c. Code
`
`12d. Code
`
`Retirement plan
`
`Third-party slck pay
`
`120. Code
`
`12d. Code
`
`15. State
`MN
`
`Employers state ID number
`6538411
`
`16. State wages, tips.
`213695.81
`
`17.State income tax
`12572 . 61
`
`15. State
`MN
`
`Employer's state ID number
`6538411
`
`16. State wages, tips.
`213695.81
`
`17.State Income tax
`12572 . 61
`
`18. Local wages, tips, etc.
`
`19. Local income tax
`
`20. Locality name
`
`18. Local wages, tips. etc.
`
`19. Local income tax
`
`20. Locality name
`
`Form W-2 Wage and Tax Statement
`
`2021
`
`Denaflment 0' me Treasury "115ml Revenue Serviw
`
`Form W-2 Wage and Tax Statement
`
`202 1
`
`DEPEI'VT'EHl 0"" Treasury '"lema' REVENUE SW68
`
`